ML20215M192

Proposed Tech Specs,Incorporating Revised Surveillance Requirements

ML20215M192
Person / Time
Site:	Fort Calhoun
Issue date:	06/22/1987
From:	OMAHA PUBLIC POWER DISTRICT
To:
Shared Package
ML20215M167	List: ML20215M164 ML20215M180 ML20215M192
References
NUDOCS 8706260305
Download: ML20215M192 (8)

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- 3.0 SURVEILLANCE RE0VIREMENTS ]

3.0.1 Surveillance Requirements shall be applicable during the operational modes or other conditions specified in individual Limiting Conditions for Operation unless otherwise stated in a 1 specific surveillance requirement.

3.0.2 Each Surveillance Requirement shall be performed within the  !

specified time interval with:

a. A maximum allowable extension not to exceed 25% of the {

surveillance interval, and  !

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b. A total maximum combined interval time for any three i consecutive surveillance intervals not to exceed 3.25 times I the specified surveillance interval. ]

BASIS l i

Specification 3.0.1 provides that surveillance activities necessary to insure i the Limiting Conditions for Operation are met and will be performed during the .I modes or other conditions for which the Limiting Conditions for Operation are 1 applicable. Provisions for additional surveillance activities to be performed I without regard to operating mode or other conditions are provided in the )

individual surveillance requirements. I The provisions of Specification 3.0.2 provide allowable tolerances for performing surveillance activities beyond those specified in the nominal surveillance intervals. These tolerances are necessary to provide flexibility i because of scheduling and operational availability considerations. The tolerance values, taken either individually or consecutively over three test intervals, are sufficiently restrictive to ensure that the reliability associated with the surveillance activity is not significantly degraded beyond that obtained from the nominal specified interval.

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3-0 2 Attachment A k[ ho$

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30 SURVEILLANCE REQUIREMENTS 31 Instrumentation and Control Applicability i

1 Applies to the reactor protective system and other critical instru-mentation and controls.

Objective 1

To specify the minimum frequency and type of surveillance to be applied to critical plant instrumentation and controls. l l

Specifications Calibration, testing and checking of instrument channels, reactor  ;

protective system and engineered safeguards system logic channels and ]

miscellaneous instrument systems and controls shall be performed j as specified in Tables 3-1 to 3-3, subfect4o-the-fol-lovingt j l

a. /. maximum-allovableaxtension-not-to-exceed-2 %

-o f-t he-surve i l-lan c e-inte rval-unle s s-o the rwi se specified ,-and- l

b. ^ total-maximum-combined-interval-time-for-any4 con s ec utive-- surveil-lan c e-fun ct ion s-not--to-ex c eed-3125  ;

t-imes-the-specified-interval .  !

Basis l Failures such as blevn instrument fuses, defective indicators, and l faulted amplifiers which result in " upscale" or "downscale" indica-tion can be easily recognized by simple observation of the functioning of an instrument or system. Furthermore, such failures are, in many ,

cases, revealed by alarm or annunciator action and a check supple- j ments this type of built-in surveillance. I

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Based on the District's experience in operation of conventional power plants and on reported nuclear plant experience, a checking i frequency of once-per-shift is deemed adequate for reactor and j steam system instrumentation. Calibrations are performed to i

ensure the presentation and acquisition of accurate information. l l

The pover range safety channels are calibrated daily against a calorimetric balance standard to account for errors induced by j changing rod patterns and core physics parameters.

Other channels, subject only to the " drift" errors, can be expected to remain within acceptable tolerances if recalibration is performed at each refueling shutdown interval.

i 3-1 e .

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,.0 SURVM'1 LLANCM REQUIREMENTQ h- 3. 2 squinment and samnling Tests Applicability Applies to plant equipment and conditions related to safety. i

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Objective To specify the minimum frequency and type of surveillance to be applie'l to critical plant equipment and conditions.

Specifications Equipment and sampling tests shall be conducted as specified in Tables 4-h ani 3-5 The specified latervals moy be edjusted-tomecommodate g

-e t est--eehedules-exeept--that-the-inbervel-eheH-no+c-exeeed-1123 . i

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.. thc spc Pici intmeh I 3asin The equipment testing and system sampling frequencies specified in Tables 3-b and 3-5 are considered adequate, based upon ' experience, to maintain the status of the equipment and systems so as to assure safe operation. Thus, those systems where changes might occur relatively

,, rapidly are sampled frequently and those static systems not subject to changes are sampled less frequently. l The control room air treatment system consists of high efficiency particulate air filters (HEPA) and the charcoal adsorbers. HEPA filters are installed before the charcoal adsorbers to prevent clogging of the iodine adsorbers. The charcoal adsorbers are installed to reduce the potential intake of iodine to the control room. The in-place test ,results will confirm system integrity and per forman ce.- The laboratory carbon sample tests results should indicate methyl iodide removal efficiency of at least 90 percent for expected accident conditions. ~  ;

i The opent fuel storage-decontamination areas air treatment system is designed to filter the building atmosphere to the o~xiliary building vent during refueling operations. The charcoal adsorbers are installed to reduce the potential release of radioiodine to the environment. In-place testing is performed to confirm the integrity of the filter cyctem. The charcoal adsorbers are periodically sampled f 1

to, insure capability for the removal of radioactivity iodine.

j Amendment, No.15,[ 3-17

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3. 0 - SURVEILLANCE REQUIREMENTS 3.10 Reactor Core Parameters Anplicability ,

Applies to reactor. core parameters that affect shutdown margin, MTC, linear heat rate and DNB margin.

Objective To require evaluation of reactor core parameters. >

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Specification )

~ The ec144rction, cheching, and tc; ting caccifica in thc fcilswiL6 pare '

. graph: i; subject.to,

u. -^A naxim- ellewable--extension -net-to cxceed 05% of the=

- ;urvcillancc intcrval, ad L. A Lotal m im- wmbinua intuivol tile fui oy 3 can-

- s e cutive . e w . e illance-funethne-net-to- ex;ced 3. 25

.___- times the cpecifi& inter-val.- 1

,:,,, (1) Shutdown Margin

a. The shutdown margin shall be determined:

1. By verifying that the CEA group withdrawal is above the Transient Insertion Limits of Specification 2.10.2 when-ever the reactor is in hot standby or power operation l con-ditions at least once per shift, or i

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2. By considering the following factors whenever the re-  !

actor is in hot or cold shutdown at least once per day.

(i) Reactor coolant' system boron concentration; (ii) CEA position; j

(iii) Reactor coolant. system temperature; (iv) Fuel burnup;. ,

t (v) Xenon concentration; and (vi). Samarium concentration..

b. The overall core' reactivity balance shall be compared to pre-1 dicted' values to demonstrate agreement with + 1.0% Ak/k at least once per 31 EFPD. The predicted reactivity values shall

- beadjusted(normalized)tocorrespond'totheactual/corecon-ditions prior to exceeding a cycle burnup of 2000 MWD /MTU

.after each refueling..

Amendment No. / J ,)MI, 63-

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• l 3.0 SURVEILLAITCE REQUIREMEITS 3.12 Radioloeical Waste Sampling and Monitoring

, 3.12.1 Liquid and Gaseous Effluents Applicability _

Applies to the sampling, monitoring, and testing used for liquid and gaseous effluents. -hopecif4+4 **unencic m.y 4 e-edfusted h

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' ate =cpw4ewhedul+*-anap.t-that=varianca chrud A_ ret ecced [

1.G LL w6- ihe-specified-duLc& ml. _

Objective To ensure that radioactive liquid and gaseous releases frem the facility are maintained as icv as reasonably achievable and within the limits specified by Specification 2.9.1(1) and 2.91(2).

Specificatiens (1) Licuid Effluents

a. Radioactive liquid vaste sampling and activity analyses shall be performed in accordance with Table 3-11. The results of these analyses shall be used vita the calculational methods in the ODCM to assure that the concentration at the point of release is limited to the values in Specification 2.9.1(1)a.

b. Prior to release of each batch of liquid effluent, the batch shall be mixed, sampled, and analyzed fer principal gamma emitters. When operational or other '. imitations preclude specific gamma radionuclide analysis of each batch, gross radioactivity measurements shall.be t.ade to estimate the quantity and concentrations of radios.ctive materials released in the batch, and a weekly sample conposited from proportional 4iquota from each batch released during the week shall be analyze 4 Tor the principal gamma-emitting radionuclides.

c. The overboard header radiation monitor shell have a:

(i) Source check prior to any release of radioactive materials from the monitor or the hotel vaste tanks.

(ii) Quarterly channel functional test.

(iii) Channel calibration at "R" frequency (every 18 months),

d. The steam generator blevdown radiation monitors shall have:

(1) Daily channel checks.

(ii) Monthly source checks.

3-69 AmendmentIlo.26,(([

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3. 0 SURVEILLANCE REQUIREEITS l D 3.15 Fire Protection System Aeolicability Applies to fire detection and fire extinguishing subsystems in nuc-lear safety related areas and other areas which may impact on safety related systems.

Objective l

To ensure the operability of the fire protection system in nuclear j safety related systems. -eurvei-1-lance-freq+tencies%pecified-below- I taha n~heve-e- klerant: c f-10% I Sneci fications l (1) Each fire detector listed in Table 2-7 and in containment shall be demonstrated operable: I

a. At least once per 6 months by performance of a channel functional test and a test of the supervision circuitry.

b. Testing interval for fire detectors which are inaccessible due to high radiatic or require an equipment alignment not used in power operation may be extended until such

b. . . time as the detectorr become accessible for a minimum of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. However, the shutdown need not be extended I solely for the purpore of this testing. Such detectors shall be functional]y tested at a maximum interval of I once per refueling cycle.

(2) The fire suppression water system shall be demonstrated oper-able:

a. At least once per month by starting each pump and oper-ating it for at least 15 minutes,

b. At least once per month by verifying that each valve in the flow path is in its correct position,

c. At least once per 12 months by cycling each testable valve (those which can be cycled without endangering the safety of equipment) in the flow path through at least one complete cycle of full travel.

d. At least once per 18 months by performing a system fune-tional test which includ.es:

1. Verifying that each pump develops at least 1800 gpm at a system head of 260 feet,

2. Cycling each valve in the flow path that is not testable during plant operation through at least one complete cycle of full travel, and Amendment No. 3-80

Attachment B )

l DISCUSSION, JUSTIFICATION AND l NO SIGNIFICANT HAZARDS I CONSIDERATIONS ANALYSIS

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i In 1977, OPPD was cited for a violation for not performing a surveillance test required by the Technical Specifications. The surveillance was not performed due to the fact that the plant was in a refueling shutdown at the time, and the q particular piece of equipment was not required to be operable. i l

0 PPD responded to the violation by stating that an Application for Amendment of i Operating t.icense to add applicable modes to the Surveillance Requirements j would be forthcoming. In 1977, OPPD submitted the first revision to the '

Application for Amendment. There was considerable disagreement between NRC Staff and OPPD, primarily resulting from the NRC's desire that OPPD propose standard Technical Specifications. The issue was placed on hold for several ,

years and it was recently noted that the NRC considers that the Application was I withdrawn although formal notification to that effect was never made. l l

In a conver,sation with the NRC Project Manager in early 1986, a possible resolution was suggested. Accordingly, OPPD proposes to add a general section 1 to the beginning of the Surveillance Requirements which serves a function '

similar to the " General Requirements" of Section 2.0 of the Technical Specifi- j cations. The proposed section specifies that a surveillance requirement is j only applicable during those operating modes during which the equipment must be  !

operable to meet an LC0 unless otherwise specified in the surveillance require- '

ment. The change further adds the allowance for a 25% extension to the surveillance interval, while limiting 3 consecutive extensions to 3.23 times 1 the nominal interval.

1 Thus, the first portion of the change will provide clarification and guidance i concerning when surveillance requirements are applicable, and will provide for i reasonable, but limited (+25%) extension to a surveillance interval. These changes will remedy the 1977 violation without adding applicable modes to each and every surveillance requirement. '

These general requirements which appear in other surveillance requirement sections have been removed to avoid duplication.

10 CFR 50.91(a)(1) requires that licensees requesting an Amendment provide an aralysis addressing the significant hazards criteria of 10 CFR 50.92.

A.cordingly, the following is provided:

The proposed change does not involve a significant hazards consideration because operation of Fort Calhoun Station in accordance with this change would not:

1. involve a significant increase in the probability or consequences of an accident previously evaluated. The change adds clarification to the surveillance requirements such that a surveillance is required during conditions where operability is required by the LC0 or when the surveillance is otherwise specified. This will alleviate confusion concerning when various surveillances are applicable. It will not increase the probability of any accident as no surveillances required to meet LCOs are being removed.

Attachment B (continued)

2. create the possibility of a new or different kind of accident than any previously evaluated. These changes do not alter the manner in which equipment is operated, nor does it introduce new modes of operation. The administrative clarification of surveillance applica-bility does not create the possibility of a new or different kind of accident. ,

3. involve a significant reduction in a margin of safety. Clarifica-tion of the applicability of surveillance requirements does not change the method of operation and therefore does not reduce any margin of safety.

The Commission has provided guidance concerning the application of the stan-dards for determining whether a significant hazards consideration exists by providing certain examples (51FR7751) of amendments that are not likely to ,

involve significant hazards consideration. Example (i) relates to administra-  !

tive changes to Technical Specifications, for example, a change to achieve consistency throughout the Technical Specifications. This change is similar to example (i) in that the change is intended to provide consistency with regard i to applicability of surveillance requirements. OPPD does not believe this  :

change involves significant hazards considerations.

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